AML Policy

1. Introduction and Scope

StswapP is a no KYC cryptocurrency swap service with Stellar Lumens (XLM) as a flagship asset. We are committed to ensuring our platform is never used to facilitate money laundering, terrorist financing, sanctions evasion, or any other serious financial crime. While our service is architected to protect the financial privacy of legitimate users performing XLM swaps and other exchanges, we draw a firm and unambiguous line against enabling criminal activity of any kind.

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy sets out the framework we apply to manage financial crime risk. It applies to all users of the Service, all transactions processed through the platform — including every XLM swap — and all individuals involved in operating the Service.

Protecting user privacy is a legitimate and important goal. Preventing money laundering and terrorism financing is a legal and moral obligation. These two commitments are not contradictory, and this policy reflects both without compromise.

2. Strictly Prohibited Activities

The following activities are absolutely prohibited on StswapP — including within XLM swaps and all other exchanges. Engaging in any of them constitutes a material breach of our Terms of Use and may result in immediate service refusal and disclosure to law enforcement where legally required:

• Laundering the proceeds of crime — converting, transferring, or concealing funds derived from any illegal activity
• Financing terrorist organisations, individuals designated as terrorists, or any activity connected to political violence
• Circumventing or evading economic sanctions imposed by the United Nations, European Union, United States OFAC, or any applicable international or national authority
• Processing funds derived from fraud, theft, extortion, ransomware, or any other predicate offence
• Processing proceeds from darknet market transactions, human trafficking, narcotics distribution, or other serious organised crime
• Deliberate tax evasion in violation of applicable law
• Structuring transactions to avoid reporting thresholds or evade detection

3. Transaction Limits as a Risk Control

StswapP imposes per-transaction limits as part of our risk management framework. These apply to every XLM swap and all other exchanges:

• Minimum transaction value: Equivalent to $100 USD
• Maximum transaction value: Equivalent to $282,100 USD

These limits apply equally to all users, without exception. They serve to limit our exposure to high-volume financial crime while preserving accessibility for the legitimate users our service is built for. The exact cryptocurrency equivalent of these limits — including the XLM equivalent — is displayed in the exchange widget before any order is created.

4. Our Risk-Based Controls

While we operate without collecting user identity data, we apply a substantive risk-based approach to AML/CTF compliance through the following technical and operational measures:

• Automated transaction monitoring: Our systems monitor for unusual transaction patterns, rapid sequential orders, and other behavioural indicators associated with financial crime activity across all swap pairs including XLM.
• Transaction velocity controls: Technical limits restrict the rate at which orders can be created, preventing structuring or layering behaviour.
• Blockchain address screening: We reserve the right to employ blockchain analytics tools to screen deposit and destination addresses against databases of high-risk addresses associated with sanctions, darknet markets, ransomware wallets, and other criminal activity. We may refuse service where screening indicates elevated risk.
• Discretionary service refusal: We retain the unconditional right to refuse service to any transaction or user at our sole discretion, without providing a reason and without liability for the refusal.

5. User Declarations

By using StswapP — including for any XLM swap — every user confirms, represents, and warrants each of the following at the time of every transaction:

• The funds being exchanged are legally obtained and are not, in whole or in part, the proceeds of any criminal activity.
• You are not subject to sanctions designations by the United Nations, the European Union, OFAC, or any applicable authority.
• Your use of the Service does not violate any AML, CTF, or sanctions law applicable in your jurisdiction.
• You will not use the Service as a conduit to assist any third party in violating AML or CTF regulations.
• You are not acting as an agent, nominee, or intermediary for an undisclosed third party whose use would otherwise be prohibited.

6. Cooperation with Law Enforcement

StswapP will cooperate fully with legitimate law enforcement and regulatory authorities where legally required. Where a valid legal order, subpoena, warrant, or other compulsory legal process is served on us, we will provide whatever information we lawfully hold that is relevant to that order.

We note that by design, the information we retain about any given transaction — including XLM swaps — is technically minimal: deposit address, destination wallet, currency pair, amount, and timestamp — held in session storage without persistent user identity linkage. This structural limitation on data retention reflects our privacy-first architecture and the fact that identity-less swap processing is entirely lawful in our operating jurisdiction.

We encourage any user who suspects money laundering or terrorist financing activity connected to cryptocurrency transactions to report it to their national financial intelligence unit (FIU) or relevant law enforcement agency.

7. No Protection from Criminal Liability

Using StswapP's no KYC XLM swap service does not provide any shield from criminal liability. A user who employs our platform for money laundering, terrorist financing, sanctions evasion, or any other financial crime remains fully and personally liable under the laws of their jurisdiction. The absence of identity collection on our part does not create legal anonymity where serious criminal offences are involved.

8. Staff and Operational Responsibilities

All individuals involved in operating or administering the StswapP platform are required to be aware of and comply with this AML Policy. Any suspicious activity identified in the course of platform operations will be escalated and handled in accordance with applicable legal obligations.

9. Policy Review and Updates

This AML Policy is reviewed periodically and updated to reflect changes in applicable law, evolving financial crime typologies, and the operational environment of the Service. All updates will be published on this page with a revised effective date.

10. Contact

For AML-related enquiries, to report suspicious activity observed in connection with our platform, or for compliance-related correspondence, please contact us at [email protected].